When a loved one passes away, most families assume the life insurance claim will be routine. If the coverage was provided through an employer, they often believe the process will be even simpler.
In reality, employer-sponsored life insurance claims are usually governed by ERISA, the Employee Retirement Income Security Act. ERISA is a federal law with strict procedural rules that are very different from ordinary state insurance laws. These rules frequently determine the outcome of the case before anyone ever steps into a courtroom.
Families lose ERISA life insurance claims every year, not because the coverage was invalid, but because a technical requirement was missed. Below are ten procedural traps that regularly destroy otherwise legitimate claims.
1. Missing the Administrative Appeal Deadline
ERISA plans typically give beneficiaries 180 days to appeal a denial. Some plans provide even less time. The deadline is measured from the date of the denial letter, not from the date you fully understand it.
If that appeal is not submitted on time, courts usually dismiss the case outright. Judges rarely excuse late filings, even when families were grieving or confused about their rights. Under ERISA, a missed deadline is often fatal.
2. Submitting a Weak or Incomplete Appeal
Many beneficiaries believe the appeal stage is simply a request for reconsideration. They submit a short letter stating they disagree with the denial.
That approach is dangerous.
In ERISA cases, the administrative appeal is the most important stage of the entire claim. It is often your only real opportunity to submit evidence, correct errors, and build the record. If you fail to include supporting medical records, employment documents, sworn statements, or expert opinions, you may not be allowed to add them later in court.
Courts frequently limit their review to what was submitted during the appeal. If the record is thin, the case is thin.
3. Assuming the Insurance Company Will Collect the Right Evidence
Insurance companies sometimes tell families they will gather medical records or investigate the facts. While they may request some documents, they are not responsible for building your case.
If important evidence is missing, courts generally treat that as the beneficiary’s failure, not the insurer’s. It is your responsibility to ensure that every favorable piece of documentation is included in the record before the appeal closes.
4. Failing to Request and Review the Full Claim File
ERISA gives beneficiaries the right to obtain the complete claim file. This file often includes internal notes, medical reviews, email communications, and the actual reasoning behind the denial.
Many families never request it.
Without reviewing the claim file, you may not know what evidence the insurer relied upon, whether the medical reviewer misunderstood the records, or whether critical information was ignored. Appealing without seeing the full file leaves you guessing about the real basis for the denial.
5. Overlooking the Actual Plan Language
The governing document in an ERISA case is the plan itself. This may include a master policy, plan booklet, summary plan description, and amendments.
These documents define who qualifies as a beneficiary, what constitutes active employment, how disability is measured, and what exclusions apply.
Relying on what HR told you or what the summary says can be risky. Courts interpret ERISA claims according to the plan’s precise language. If your appeal does not address those definitions directly, you may lose on technical grounds.
6. Ignoring Discretion Clauses and Standards of Review
Many ERISA plans grant the insurer discretionary authority to interpret the plan and determine eligibility. When that language is present, courts often apply a deferential standard of review.
This means the judge may uphold the denial if it was merely reasonable, even if the judge might have decided differently.
If you do not address that standard during the appeal and present compelling evidence that the decision was arbitrary or unsupported, you may be fighting uphill from the start.
7. Failing to Respond to Every Reason for Denial
Denial letters often list multiple justifications. For example, an insurer may claim the insured was not actively at work, failed to provide evidence of insurability, and fell within an exclusion.
If you respond to only one issue and ignore the others, the unchallenged reasons may independently support dismissal of your lawsuit later.
Each stated basis for denial must be addressed thoroughly and directly in the appeal.
8. Allowing the Record to Close Without Key Evidence
Once the administrative appeal is completed, the record usually closes. Courts typically refuse to consider new evidence that was not part of the administrative file.
Families sometimes discover important documents after the appeal is submitted, such as payroll records, enrollment forms, or updated medical opinions. If those materials were not included during the appeal stage, they may never be considered.
Timing is critical in ERISA claims. Waiting too long can permanently limit your case.
9. Failing to Exhaust Administrative Remedies
ERISA requires beneficiaries to complete the internal appeal process before filing a lawsuit. This is known as exhausting administrative remedies.
If you file suit before finishing the appeal, courts usually dismiss the case. In some situations, that dismissal may prevent you from refiling if deadlines have expired.
Even if the denial seems obviously wrong, the appeal process must typically be completed first.
10. Trusting Informal Communications Instead of Written Requirements
Families often rely on phone conversations with claims representatives. They may believe extensions were granted or issues were resolved based on those discussions.
Under ERISA, what matters is what is in writing and what is included in the administrative record. Verbal assurances are rarely enforceable. If a representative says something important, it should be confirmed in writing and included in the claim file.
Failure to document these communications can create procedural gaps that later harm the case.
Why Procedural Mistakes Matter So Much Under ERISA
In many ERISA life insurance cases, there is no jury. There are no live witnesses. The judge reviews a written record and decides whether the insurer’s decision complied with the plan and applicable law.
If that written record is incomplete or procedurally flawed, the court may uphold the denial even if the underlying facts favor the family.
That is why ERISA procedural traps are so dangerous. The claim can be lost on paperwork alone.
Final Thoughts
Employer-provided life insurance policies often give families a false sense of security. When a denial occurs, the rules governing the dispute are strict, technical, and unforgiving.
Understanding these procedural pitfalls early can make a substantial difference. In ERISA cases, the appeal stage is not a formality. It is the case.
If your ERISA life insurance claim has been denied or delayed, the way the appeal is handled may determine whether the benefits are ultimately paid.